Fly.io: DPA, subprocessors and transfers

Links last opened 30 October 2026. Record confirmed by a person on 16 September 2026. 4 recorded changes, listed below.

Fly.io contracts through Fly.io, Inc., registered in United States. Transfers of personal data out of the EEA are covered by EU-US Data Privacy Framework (DPF). Data regions it offers: global. Its trust center is published at https://fly.io/docs/security/. Its customer data processing agreement, also called a data processing addendum, is published by Fly.io itself; the link is below. Its sub-processor list is published by Fly.io itself; the link is below. We open those pages every day — last on 30 October 2026 — and a person last went through this record on 16 September 2026.

Contracting legal entity: Fly.io, Inc.
Country of registration: United States
Transfer mechanism: EU-US Data Privacy Framework (DPF)
A US certification scheme covered by an EU adequacy decision. Transfers to a certified US organisation need no further mechanism for the certified scope.
Data processing agreement: https://fly.io/documents/
Subprocessor list: https://fly.io/legal/sub-processors/
Security or trust page: https://fly.io/docs/security/
Data regions: global

What to put in your subprocessor list

A ready row. Replace the purpose with what your client actually uses Fly.io for.

Subprocessor	Legal entity	Country	Purpose	Transfer	DPA
Fly.io	Fly.io, Inc.	US	Hosting and infrastructure	DPF	https://fly.io/documents/

Questions people ask about Fly.io

Where is Fly.io's DPA?: Fly.io publishes its customer data processing agreement at https://fly.io/documents/. We last opened that link on 30 October 2026.
Is Fly.io's DPA the same thing as a data processing addendum?: Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. Fly.io's is at https://fly.io/documents/.
Where is Fly.io's sub-processor list?: Fly.io publishes the list of its own sub-processors at https://fly.io/legal/sub-processors/. We last opened that link on 30 October 2026.
Which legal entity does Fly.io contract through?: Fly.io, Inc., registered in United States. That is the name to put in a record of processing or a sub-processor list, not the brand.
What covers a transfer of personal data to Fly.io outside the EEA?: EU-US Data Privacy Framework (DPF). A US certification scheme covered by an EU adequacy decision. Transfers to a certified US organisation need no further mechanism for the certified scope. Whether that is enough for a particular processing operation is a judgement for the controller.
Where is Fly.io's trust center?: Fly.io publishes it at https://fly.io/docs/security/. A trust center, trust page or security page is the same thing under different names: the vendor's own account of how it protects data, and the place it keeps its certifications. It is Fly.io's page, so we link to it rather than repeat what it says.

What has changed, and when

Changes we noticed on Fly.io's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.

30 October 2026
Fly.io added Zenlayer as a subprocessor. Zenlayer will not process customer personal data until 2026-11-28.
Seen on https://fly.io/legal/sub-processors/
25 October 2026
Fly.io added ClickHouse and OpenRouter as subprocessors for audit log storage and AI model routing for internal tooling respectively, with processing of customer personal data not beginning until November 23, 2026. The vendor removed language listing Anthropic and OpenAI individually from the subprocessor list, though the policy clarifies that AI vendors including these providers are used only for internal tooling and do not receive customer data from volumes or application requests.
Seen on https://fly.io/legal/sub-processors/
27 September 2026
We recorded a change to the UK transfer mechanism.
25 September 2026
Fly.io added three subprocessors: Dropbox Sign for agreement signing, incident.io for incident response and on-call management, and Vultr for AI vendors. Organizations relying on Fly.io need to update their records of processing and data processing agreements to reflect these new subprocessors and their respective functions.
Seen on https://fly.io/legal/sub-processors/

See the 35 sub-processors Fly.io lists →

Building your own sub-processor list?

Enter your website: each service it loads, what it is for and links to its own DPA, in a minute or two. No sign-up.

Build my list

Worked out from the registry and what we have written: the country this vendor contracts from, the guides that answer the question this page raises, and the rest of the registry.

Other hosting and infrastructure

Six of them. All hosting and infrastructure in the registry · others that transfer the same way.

Subprocessor

Legal entity

Country

Purpose

Transfer

DPA

Fly.io

Fly.io, Inc.

Hosting and infrastructure

DPF

https://fly.io/documents/

Questions people ask about Fly.io

Where is Fly.io's DPA?

Fly.io publishes its customer data processing agreement at https://fly.io/documents/. We last opened that link on 30 October 2026.

Is Fly.io's DPA the same thing as a data processing addendum?

Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. Fly.io's is at https://fly.io/documents/.

Where is Fly.io's sub-processor list?

Fly.io publishes the list of its own sub-processors at https://fly.io/legal/sub-processors/. We last opened that link on 30 October 2026.

Which legal entity does Fly.io contract through?

Fly.io, Inc., registered in United States. That is the name to put in a record of processing or a sub-processor list, not the brand.

What covers a transfer of personal data to Fly.io outside the EEA?

EU-US Data Privacy Framework (DPF). A US certification scheme covered by an EU adequacy decision. Transfers to a certified US organisation need no further mechanism for the certified scope. Whether that is enough for a particular processing operation is a judgement for the controller.

Where is Fly.io's trust center?

Fly.io publishes it at https://fly.io/docs/security/. A trust center, trust page or security page is the same thing under different names: the vendor's own account of how it protects data, and the place it keeps its certifications. It is Fly.io's page, so we link to it rather than repeat what it says.

What has changed, and when

Changes we noticed on Fly.io's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.

30 October 2026

Fly.io added Zenlayer as a subprocessor. Zenlayer will not process customer personal data until 2026-11-28.

Seen on https://fly.io/legal/sub-processors/

25 October 2026

Fly.io added ClickHouse and OpenRouter as subprocessors for audit log storage and AI model routing for internal tooling respectively, with processing of customer personal data not beginning until November 23, 2026. The vendor removed language listing Anthropic and OpenAI individually from the subprocessor list, though the policy clarifies that AI vendors including these providers are used only for internal tooling and do not receive customer data from volumes or application requests.

Seen on https://fly.io/legal/sub-processors/

27 September 2026

We recorded a change to the UK transfer mechanism.

25 September 2026

Fly.io added three subprocessors: Dropbox Sign for agreement signing, incident.io for incident response and on-call management, and Vultr for AI vendors. Organizations relying on Fly.io need to update their records of processing and data processing agreements to reflect these new subprocessors and their respective functions.

Seen on https://fly.io/legal/sub-processors/

Fly.io: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Fly.io

What has changed, and when

Building your own sub-processor list?

Where to go next

Other hosting and infrastructure

Fly.io: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Fly.io

What has changed, and when

Building your own sub-processor list?

Where to go next

Other hosting and infrastructure